Generally, yes, subject to the reasonableness requirement of 2 CFR 200.404. Recipients must demonstrate that they acted with prudence in scheduling the travel or event requiring facility rental for in-person events given the uncertainties stemming from COVID-19.
Any determinations by authorized EPA officials provided to recipients that travel or facility rental cancellation costs are allowable will include a statement indicating that the recipient should not assume additional funds will be available if the costs for cancellation or other fees result in a shortage of funds to eventually carry out the award.
A. Travel. At this time, allowability of travel cancellation costs will be assessed on a case by case basis. Recipients should document the facts concerning any cancellation, e.g., carrier cancellation policies as adjusted for waivers due to the COVID-19 public health emergency, to substantiate the charging of cancellation costs and provide this information to the GS and PO. Authorized EPA Officials are to consider whether recipients can offset the impact of COVID-19 uncertainties by shifting funds budgeted for travel to other activities that can be carried out remotely. Recipients should explain why the travel was necessary in light of remote work options.
B. Meeting Facilities. As with travel, the allowability of meeting facility cancellation fees will be determined on a case by case basis. Facility cancellation fees must be based on the venue’s standard practices and consider any cancellation fee waivers or discounts offered due to the COVID-19 public health emergency. Recipients must provide the PO and GS with documentation to support payment of meeting facility cancellation fees. In making allowability determinations, Authorized EPA Officials consistent with 2 CFR 200.404 are to consider whether recipients have been prudent in minimizing expenditures for obtaining facilities for in-person events given the uncertainties stemming from COVID-19. Recipients should explain why incurring the meeting facility costs were necessary in light of remote meeting options.
C. Personnel compensation and contractor costs. Reasonable personnel and contractor costs associated with planning the event are allowable even if the event has been cancelled as long as carrying out the event is within the scope of work for the grant. Recipients should explain why incurring the meeting planning costs were necessary in light of remote meeting options.